September 26, 2023
The bottom line, upfront: SNAP recipients will receive their October payments, even if a government shutdown occurs.
Background on EBT Payments
The Supplemental Nutrition Assistance Program (SNAP) is a delicate partnership of public and private entities. While it is a federal program, each state agency works with their own Electronic Benefit Transfer (EBT) vendor and decides its own disbursement date. Each month, states must transmit an electronic file with the information about each eligible SNAP household’s benefit amount to the EBT vendor by mid-month, so that the EBT vendor can process the data and load individual EBT cards with the next month’s SNAP benefits for that household.
Funding the Government
Congress must enact interim or full-year appropriations by October 1, the beginning of the federal fiscal year for agencies and programs whose continued operation depends on annual appropriation acts. A failure to do so creates a funding gap, at which point the federal government begins a “shutdown” of affected activities, including the furlough of nonessential personnel and curtailment of agency activities and services as we saw in 2019. To avoid a government shutdown, Congress may enact short-term measures, known as “continuing resolutions” (CRs), to keep the government funded for a few days, weeks, or months at previous levels until final budgeting decisions are made.
If Congress fails to pass either full-year appropriations bills or a continuing resolution, the federal government will shut down all programs dependent on annual appropriations, including SNAP. In 2021, the U.S. Department of Agriculture ( USDA) issued a contingency plan stating that SNAP operations could continue during a lapse in appropriations based on multiyear carry-over funds; contingency reserves; and quarterly apportionment of funds by the Office of Management and Budget under the continuing resolution. More importantly, Food and Nutrition Service’s updated accounting process considers the upcoming month’s benefits to be “obligated” in the prior month when issuance files are sent to the EBT vendor and extends the current federal fiscal year’s appropriations to cover the benefits for the first month of the next federal fiscal year. In this case, October benefits are obligated in September. Accordingly, there is no need for SNAP recipients to worry about missing their October payments if a shutdown were to occur.
Impact of a Shutdown
If a shutdown were to occur and continue past mid-October, there is a $6 billion in SNAP contingency reserve funding carrying into fiscal year 2024, which may be used to cover SNAP costs. If, however, USDA fails to instruct states to proceed with transmitting the necessary electronic files in order to timely issue November benefits, November SNAP benefits may be delayed or interrupted entirely. This is due to the internal processing of states that varies across the country. All states have a date they have determined when they must start the process to timely issue the upcoming month’s SNAP benefits to recipient households. If any state misses that deadline to begin the issuance process on that date, harm to households is almost certain to occur, as benefits to individual households will be delayed.
While many states may want to plan for this contingency, USDA has previously informed states that if they proceed with the issuances in the absence of an annual appropriations bill, using state funds, they are liable for their actions without any guarantee of federal reimbursement. This previous guidance may make states hesitant to utilize their state budget to upfront the cost of benefits.
Contact your Members of Congress now and let them know how millions of individuals with low incomes will be affected if there is a government shutdown. If there is a shutdown, engage with policymakers to urge them to quickly pass a CR so SNAP benefits will remain uninterrupted.